Privacy Policy

Introduction – Our Approach to Privacy

Pathtide Capital Group Inc (PTCG). ("Pathtide", "Company" "us" or "we") is committed to protecting your privacy and following the laws requiring it to do so. Pathtide operates the following: a website located at https://www.Pathtide.com ("Website") and a cloud-based property management platform or application — https://app.Pathtide.com ("Cloud App") and additional products and services which may vary from time to time (the Website, Cloud App and other services and products shall be referred to collectively as "Offerings"). This Privacy Policy details topics such as how we maintain, collect, use and disclose information that can identify or lead to the identification of an individual (“Personal Data”) and users of the Offerings (collectively “Visitors”).

Please note that we may also collect information that cannot be associated with a specific individual. However, if such information is combined with Personal Data, we will treat the combined information as Personal Data.

When you visit, access or use any of the Offerings, whether or not you choose to enter into or register for a free or paid subscription plan, your Personal Data will be processed in accordance with this Privacy Policy.

What Personal Data do we process?

Pathtide collects Personal Data about You when, amongst other methods, you contact us, visit any of our websites, register with Pathtide, express interest in obtaining information about Pathtide, its products or services, when you participate in activities on any of Pathtide’s websites, use any of Pathtide’s services or products, and/or use any of the services or products provided by Pathtide’s partners, third party providers, integrated providers, and affiliates.

Data Collected

The Information Pathtide collects from Visitors varies depending on a variety of factors, including the products and features you use, the context under which you interact with Pathtide and/or Pathtide’s Offerings. The following is a non-exhaustive list of Information we collect or may collect from you:

Website Visitors

• Name (first, middle, last)
• Email
• Login (username) and Password
• Job title and function (i.e. role)
• Portfolio type
• Timeline
• Browser language
• Geographical location
• IP address
• Contact preferences
• Phone number
• Mailing and billing address
• UTM (Urchin Tracking Model) parameters of which channel the visitor came from
• Region
• Tracking Distinct ID
• Referrer
• Landing page
• Campaign ID
• Keyword ID
• Adgroup ID
• Google Click ID
• Facebook Click ID
• Microsoft Click ID
• First Website Visit At

In addition, for Pathtide Leads

• Payment data including bank, credit and debit card identifiers (i.e., last 4 digits, type of credit card)
• Social media and email provider logins and profiles
• Phone number, email address, and fax number
• Gender
• Photo(s)
• Your company information, logo, and tax identification number
• Portfolio type

In addition, for Pathtide Subscribers, Pathtide Customers, and other Users (including tenants, prospects and property owners)

• Date of birth
• Your social security number and/or other government issued identification number of information
• Information and files provided by You when filling out an online Rental Application
• Images of your driver's license, government issued passport, identification, and national identification card
• Your activity while accessing, visiting, navigating and using Pathtide’s Offerings, Pathtide, its software, its website, its services, products and services and products offered by 3rd Party Providers (as defined in the Property Manager Terms of Service) via Pathtide

Pathtide may also collect information, which may include Personal Data, from third party sources, such as public databases, affiliate programs, data providers as well as via sources including:

• Your Media Access Control (MAC) address, computer (including phone and tablet) type, screen resolution, type of operating system as well as the version, and web browser type and version
• Cookies, files that are stored in your computer/phone/tablet either temporarily or permanently, which permit Pathtide to collect data/information including your browser, your language preference, time spent on Pathtide’s Offerings, and tracking pages you visit
• Web Beacons/Clear GIFs/Pixel tags (and other similar technologies)
• Via your Internet Protocol address (“IP Address”)

What are the purposes of processing?

We may use and share Personal Data we collect for the following purposes:

• To process your order and manage your account;
• To provide you with materials (marketing, administrative, or otherwise) and information we believe may be of interest to you, including advising you of updates on Offerings, informing you of upcoming events, and informative materials concerning: changes to our terms, conditions, and policies (including this Privacy Policy); other administrative information; and Offerings (new & old);
• To call you, send you text messages, calendar invite reminders, emails, event reminders, and the like. Be advised that by providing Pathtide Your phone number, (a.) You consent to receive texts, calls and emails from Pathtide about its products and services, (b.) message and data rates may apply, and (c.) You can reply STOP to opt out from text messages at any time. Please know that Your consent to receiving text messages is not a condition of any purchase;
• To fulfil and/or manage your requests;
• To allow you to provide materials and/or information to your respective users, clients, residents, tenants, applicants, owners, managers, or vendors;
• To allow you to add your contacts to/for Pathtide’s referral programs. By doing so, you are informing Pathtide that you are lawfully authorised to use and provide us with your contact’s name, phone number, email address, and other information requested by Pathtide and provided by you;
• To allow your partaking in promotional activities, contests, and similar activities (collectively, “Events”), and to manage and run such Events. Be advised that such Events may have additional rules governing how we use, maintain, collect and disclose Information;
• To allow you to personalise your experience on Pathtide’s Offerings;
• To enable our third-party service providers to provide you/your business with services including: credit, debit, ACH and other financial processing services; email and text messaging services (however, such third party providers may not text you without your prior express consent which you may give or deny in your sole and absolute discretion and which is not a condition for receiving services); renter’s insurance; criminal, credit and eviction history background check(s) and identity verification(s); website hosting; customer service; auditing; marketing; document signatures; listing syndication; security deposit and security deposit alternatives; loan and other financing services;
• To suggest and/or provide products, services and offers that we believe you might find to be of interest;
• For security purposes, to protect the Offerings, to enforce our terms, conditions and policies, to respond to regulatory requirements and/or requests, and/or to enforce any agreements that Pathtide has with you;
• To respond to your questions, comments and concerns;
• To aid in navigation and in the more efficient and/or effective display of data, materials and information, and to personalise your experience;
• For our commercial and business purposes, including statistical analysis and research and development;
• To try and diagnose technical issues, including software error(s) or bug(s);
• For online, email, marketing, usage, response rate and other tracking purposes.

What is our legal basis for processing?

The Legal Basis for Processing – GDPR

The General Data Protection Regulation (GDPR) is a unified data protection law that came into effect on May 25, 2018 in the EU. The law strengthens the protection of personal data belonging to EU individuals and gives them more control over the use of their personal data within the EU and internationally. GDPR applies to all businesses that process personal data for EU residents.

We believe that GDPR is an important means to ensuring the rights of individuals to control access to their personal information and we are committed to supporting our customers in meeting their GDPR requirements. We have updated our product and business operations to comply with GDPR guidelines, meeting our requirements as both a data controller and data processor. These updates are reflected herein.

This policy also identifies how personal data is collected and kept secure, and how data subjects may contact Pathtide regarding their information.

Pathtide’s industry-leading security measures protect data stored within. For general information on GDPR, please visit the Information Commissioner’s Office website.

With whom do we share your Personal Data?

We do not rent or sell any Personal Data, and no such activity has occurred in the prior 12 months. In the event that Pathtide changes its practices and engages in the sale of personal information as regulated by law, we will provide advance notification to impacted individuals and offer the ability to opt in/opt out in accordance with regulatory requirements.

We may share Personal Data when authorized or otherwise requested by You, for example, when You use or implement one or more 3rd Party Provider Services (as defined in Pathtide’s Terms of Service).

We may share Personal Data with the following categories of recipients:

• Trusted vendors, business partners, suppliers, subcontractors and service providers – these recipients process Personal Data we share with them only as "processors" or "service providers" (as these terms are defined in the applicable laws), and are only authorised to use your Personal Data only as necessary to provide certain services to us. They may provide us with different services, such as fraud detection and prevention, storage, analytics, advertising, financial products and services, payment services, loan services, security deposit alternatives, marketing and listing syndication, renter’s insurance, address verification providers and so on;
• Analytics and search engine providers that assist us in the improvement and optimization of our Website;
• Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you;
• Payment processors for the purpose of fulfilling relevant payment transactions.

We may share information, including Personal Data, in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale of an asset or transfer in the operation thereof) of Pathtide. In the event of the above, the acquiring company or transferee will assume the rights and obligations as described in this Privacy Policy.

We may also disclose Personal Data, or any information you submitted via the Offerings, if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, subpoena, legal process or governmental or administrative request; (ii) enforce our policies (including our agreements), including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) establish or exercise our rights to defend against a legal claim or potential legal claim; (v) prevent harm to the rights, property or safety of us, our affiliates, our Users, yourself or any third-party; (vi) for the purpose of collaborating with law enforcement agencies; and (vii) in case we find it necessary in order to enforce intellectual property or other legal rights.

Testimonials. With consent, we may display personal testimonials of satisfied customers on our site, along with other endorsements.

We utilize cookies and tracking technologies as set forth in the Cookie Policy. Under some circumstances, these technologies may be deemed a “sharing” of personal information under applicable privacy laws.

Use of Local Storage and Session Storage

In addition to other cookie and tracking technologies, Pathtide also uses local storage and session storage technologies to, amongst other reasons, enhance your user experience and improve the functionality of our services. These local and session storage mechanisms allow us to save small amounts of data directly on your device, which may include preferences, settings, or other necessary information.

Local Storage: Data saved in local storage remains on your device even after you close your browser or navigate away from our website. This helps us provide a consistent experience by remembering your preferences for future visits. For example, we may use local storage to save your language selection or other customization settings.

Session Storage: Data saved in session storage is temporary and only persists while your browser is open. This data is automatically deleted once you close your browser. Session storage is typically used to maintain session-specific information, such as temporary form inputs or navigation history.

We do not use local storage or session storage to collect sensitive personal information without your explicit consent. You can manage or delete data stored in local and session storage through your browser’s settings. Please note that disabling these storage mechanisms may affect your ability to use certain features of our website.

All voluntary sharing of Personal Data as described above is only done in accordance with an applicable contractual engagement.

Categories of Personal Data Collected or Disclosed in the Preceding 12 Months

International transfers of Personal Data

Since Pathtide operates globally, it may be necessary to transfer data, including Personal Data, to jurisdictions other than your own, including outside of the UK or the European Union. In these instances, we ensure that these international transfers of your personal information are made pursuant to appropriate safeguards, and we will take suitable steps to ensure that your personal data is treated just as safely and securely as it would be within the EU and under the General Data Protection Regulation (“GDPR”) or the UK General Data Protection Regulation (“UK GDPR”). Such measures shall include, but are not limited to, having Data Processing Agreements with applicable subprocessors and ensuring that such subprocessors have adequate security and data protection procedures in place and which align with the GDPR or any other applicable data protection law.

How long do we retain your Personal Data?

We will only retain Personal Data for as long as necessary to provide our Offerings and to comply with our legal obligations, resolve disputes and enforce our agreements (unless we are instructed otherwise). Retention periods are determined by taking into account the nature/sensitivity and amount of information, the potential risk of harm from unauthorized use, the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we may keep records containing users' Personal Data, compliance related data, communications and anything else as required by applicable laws and regulations.

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

How do we secure Personal Data?

We take security of data seriously and take appropriate security measures in an effort to maintain the security of the Personal Data. We are continuously implementing and updating security controls to help protect your information against unauthorized access, loss, destruction, or alteration. Such controls may include industry standard intrusion detection systems, encryption of data both while in transit over public networks (e.g., Internet) and while at rest (e.g., in a database or platform), and identifying and patching exploitable software and system vulnerabilities.

We protect Personal Data that is sent through our website in transit by appropriate encryption. However, we can only move to secure areas under our control, and despite our efforts, please know that security risks can never be excluded completely and residual risks are unavoidable.

Notwithstanding this, we cannot guarantee the complete security of your personal information transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to prevent any risks. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Offerings, you are responsible for keeping this password confidential. You should not share your password with anyone.

What are your rights with respect to your Personal Data?

Under certain circumstances, depending on your jurisdiction, you may have rights under data protection laws in relation to the Personal Data we process about you:

• Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we process about you.
• Request correction of your Personal Data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your Personal Data. This enables you to ask us to delete or remove your Personal Data.
• Object to processing of your Personal Data. In certain circumstances you can object to our processing of your Personal Data.
• Request restriction of processing of your Personal Data.
• Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format.
• You have the right to withdraw consent at any time where we are relying on consent to process your Personal Data. Please note that if you withdraw your consent, we may not be able to provide certain products or services to you.
• You have the right to object to automated individual decision-making and profiling which has produced legal effects or otherwise significantly affected you, and the right to request human intervention where, in such cases, we have relied on automated decision making or profiling.

Depending on the state in which you live, you may have the following rights:

California Rights

California law provides California residents with the rights listed below.

Right to Know. You have the right to know what personal information we have collected and disclosed about you in the last 12 months, including: the categories of personal information we have collected; the categories of sources of the personal information; the categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed; the categories of personal information we have sold or shared and the categories of third parties to whom the information was sold or shared; the business or commercial purposes for collecting, selling, or sharing the personal information; and the specific pieces of personal information we have collected about you.

Right to Correct. You have the right to request that we correct inaccurate personal information.

Right to Delete. You have the right to request that we delete the personal information we have collected from you (subject to certain statutory exemptions).

Right to Access/Portability. You have the right to request a copy of the personal information we have collected about you.

Right to Opt Out. You have the right to opt out of the sharing of your personal information to a third party for cross-context behavioral advertising (as defined under California law).

You also have the right not to be discriminated against for exercising any of the rights listed above.

Sensitive Personal Information. Certain categories of personal information we collect and use to provide the Services may be deemed "sensitive personal information" under California law (such as: social security number, driver’s license, financial account or card numbers, precise geolocation, racial and ethnic characteristics, and content of mail, email, and text messages sent through our systems). We do not use or disclose sensitive personal information other than to provide our Services and as otherwise permitted by California law.

You can designate an authorized agent to make a request under the CCPA on your behalf if: the authorized agent is a natural person or a business entity registered with the Secretary of State of California; and You sign a written declaration that you authorize the authorized agent to act on your behalf.

If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.

If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: deny you goods or services; charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; provide you a different level or quality of goods or services; or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Do Not Sell or Share My Personal Information

Under California law, for example, the California Consumer Privacy Act of 2018 (“CCPA”), certain types of data sharing—such as for cross-context behavioral advertising—may be considered a “sale” or “sharing” of personal information.

Pathtide may share limited information about You with others, including but not limited to law enforcement, third party service providers, analytics partners, and advertising platforms for reasons including improving performance, user experience, and marketing efforts.

If you are a California resident, you have the right to opt out of this type of data sharing. To exercise this right, please either contact us via www.Pathtide.com/contact or email us at support@Pathtide.com.

We will stop sharing your information for these purposes, unless you choose to re-enable sharing at a later time. This does not affect Pathtide’s ability to provide You with goods or services you’ve requested, perform under a contract that Pathtide’s entered into with You, maintain the functionality or security of Pathtide’s systems, nor does it apply to information that Pathtide must retain to comply with legal obligations or exercise rights provided by law.

Colorado, Connecticut, Texas, Utah, and Virginia Rights

Right to Access. You have the right to know and see what personal information we have collected about you.

Right to Correct. You have the right to request that we correct inaccurate personal information (Colorado, Connecticut, Texas, and Virginia only).

Right to Delete. You have the right to request that we delete the personal information we have collected about you.

Right to Data Portability. You have the right to request a copy of the personal information we have collected about you.

Right to Opt Out. You have the right to opt out of targeted advertising (as defined by each states' respective law).

Oregon Rights

Right to Access. You have the right to know what personal information we have collected and disclosed about you, including: the categories of personal information we have collected about you; a list of third parties to whom we disclosed your personal information for a business purpose; and a copy of the personal information we have collected about you.

Right to Correct. You have the right to request that we correct inaccurate personal information.

Right to Delete. You have the right to request that we delete the personal information we have collected from you (subject to certain statutory exemptions).

Right to Opt Out of Targeted Advertising. You have the right to opt out of targeted advertising (as defined under Oregon law).

If you wish to exercise any of the above-mentioned rights or raise any concern, please contact us in accordance with the information mentioned at the bottom of this Privacy Policy. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Appeal Process

In the event you disagree with the outcome of a request, you may initiate an appeal by contacting us. Please note that an appeal should only be submitted after you have received a response to your original request.

If you are located in the EEA or the United Kingdom, you also have the right to lodge a complaint with the competent data protection supervisory authority in your country. You can find a list of authorities in the EEA here. You can reach the UK supervisory authority here.

Please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements.

Personal Data associated with minors

Our Offerings are not intended for minors below the age of 16 years or otherwise below the legal age for providing consent that is not subject to authorization by the holder of parental responsibility, in accordance with the laws in the jurisdiction your reside (“Age of Consent”), and we will not knowingly collect Personal Data from children. If we become aware that a user is under the Age of Consent, we will remove their information from our files. We reserve the right to request proof of age at any stage so that we can verify that minors or unauthorised individuals are not using the Offerings.

Artificial Intelligence and Automated Systems

To enhance our services, Cloud App and Offerings, improve efficiencies and user-friendliness, and provide you with new and innovative features, Pathtide utilizes Artificial Intelligence (AI) and automated systems. We are committed to using these technologies responsibly and transparently. This section of our Privacy Policy explains how we use AI and automated systems, the general types of personal information involved, and your rights in relation to these technologies.

Please be aware that: Pathtide’s AI feature is for informational purposes only and should not be considered legal, financial, or accounting advice. The accuracy of Information provided by AI cannot be guaranteed. We may store and review your interactions with our AI, for reasons including but not limited to monitoring its performance, improving our Offerings, and ensuring compliance with our various terms of service and agreements (located at www.Pathtide.com/legal).

What We Mean by "Artificial Intelligence" and "Automated Decision-Making"

Artificial Intelligence (AI): When we refer to AI, we mean technological systems that are designed to perform tasks that would typically require human intelligence. These tasks can include learning from data, identifying patterns, making predictions, generating content, or assisting in decision-making processes related to our Offerings.

Automated Decision-Making (ADM): This refers to decisions made about you using technological means, based solely or significantly on the automated processing of your personal information, which could produce legal effects concerning you or similarly significantly affect you (for example, in relation to your eligibility for certain services).

Personal Information Processed by Our AI Technologies

Our AI technologies may process various categories of personal information to function effectively and provide you with our Services. The specific information processed depends on the AI feature being interacted with, the personal information available within the account being used, and the Offerings being used. While the below is not an exhaustive list of the information we may process, such information may include:

• Identity and Contact Data: Such as name, email address, phone number, SSN (or other such identifying information), date of birth, payment information, transaction history and account credentials. It may also include whether you are a property manager, user, owner, tenant, vendor or prospective user.
• User Content: Data that you provide to Pathtide (or is provided by you to a third party who in turn provides such to Pathtide) via its various Offerings and services, including your prompts and other content you upload, such as files, images, and audio.
• Property Data: Information related to properties you manage, own, live/work in, or are interested in, such as addresses, unit details, lease terms, listing details, and property characteristics.
• Financial Data and Personal Information: Financial, insurance, identity and other similar types of materials and information, input by you, others, as well as processed through our platform and offerings. For example, such information might relate to financial or insurance transactions, such as rent payment history, insurance coverage(s), fees, and accounting data.
• Screening and Application Data: Information you provide in rental applications or that we obtain for tenant screening purposes, which may include employment history, income verification, credit information, criminal history (processed via partners like TransUnion), and other background check information.
• Communication Data: The content of communications exchanged through the Pathtide platform, such as text, email, voice, announcements, push and other messages, including those sent/received via tenant or owner portals as well as interactions with our support tools.
• Maintenance Data: Details of maintenance requests, work orders, vendor communications, and related property condition information.
• Usage Data: Information about when, where (i.e., location) and how (and how often) you navigate and interact with the Offerings, the features you use, your preferences, IP address, clickstream data, browser type and settings, and such similar information.
• Device and Technical Data: Information from your device, such as IP address, browser type, operating system, and unique device identifiers, primarily for security and operational purposes.

How We Use AI and Automated Systems

Pathtide uses AI and automated systems for various purposes, such as improving both our services and Offerings, providing overall efficiencies, and other business purposes that we deem advisable in our reasonable discretion. These purposes include:

• Service Provision and Enhancement: Automating routine tasks (e.g., rent payment reminders, communications, accounting tasks, lease renewal notifications), streamlining workflows (e.g., maintenance request processing), and providing analytical insights (e.g., property, unit, tenant performance reporting).
• Personalization: Tailoring your experience within the Pathtide platform, such as customizing dashboard information or suggesting features relevant to your needs.
• Tenant and Applicant Screening: Our AI tools may assist in evaluating rental applications by processing information related to creditworthiness, rental history, income, and other relevant factors to help property managers make informed decisions. Final screening decisions should involve human review, particularly where required by law or our policies.
• Property Valuation and Analytics: We may use AI to analyze market data, property characteristics, and other relevant information to provide estimated property valuations and market insights. These are typically for informational purposes.
• Predictive Maintenance: AI may be used to analyze data from properties to identify patterns that may predict potential maintenance needs, helping to proactively address issues.
• Communication and Support: Our AI feature, which is powered by one or more technologies from Intercom, OpenAI's ChatGPT, Anthropic’s Claude, and Google’s Gemini, is available to provide general information, answer questions and take specific actions that you request of it.
• Fraud Prevention and Security: We may utilize AI to help detect, prevent, and mitigate fraudulent activity, unauthorized access, and other security threats to our platform and your data.
• Product Development and Improvement: We also analyze aggregated and/or de-identified usage patterns, user feedback, and system performance data, sometimes with the assistance of AI, to understand how our Offerings are used, to identify areas for improvement, and to develop new features and AI-driven tools.
• Intelligent Lease Management: AI may be used to assist in drafting, managing, or analyzing listings, external communications, and lease documents. For instance, generative AI tools might help create lease templates based on provided parameters. Such AI-generated content is typically intended as a starting point and may be subject to your review and modification.
• Other Business Purposes: For example, automating workflows with and/or providing information/materials to a third party for your benefit, the benefit of another user, or Pathtide’s.

Data for AI Model Development and Improvement

To develop, train, and improve the accuracy and effectiveness of our AI models and Offerings, Pathtide may use personal information. This may include data you provide to us, provided to us by others (e.g. your property manager), generated through your use of our Offerings, or publicly available information. When using personal information for AI model development and improvement, we are committed to protecting your privacy. We implement measures such as:

• De-identification and Aggregation: Where feasible and desirable in our discretion, we will de-identify or aggregate personal information so that it does not directly identify you before using it for training or development purposes.
• Secure Environments: AI model development and training are conducted in secure environments with appropriate access controls. Our legal basis for such processing is typically our legitimate interest in improving and innovating our Offerings, balanced with appropriate safeguards for your rights and freedoms.

We retain data used for AI model training for as long as we deem necessary (but not longer than lawfully permissible) for these development and improvement purposes, in accordance with our data retention policies.

Automated Decision-Making (ADM) and Your Rights

Some of our AI-powered features may involve Automated Decision-Making (ADM), which could have a significant or legal effect on you. It is important that you understand that while AI may assist, the final decision should always involve human judgment and oversight (i.e., by you or your authorized representative).

You have certain rights in relation to ADM, which are detailed in the 'Your Choices and Rights Regarding Our Use of AI' section and any applicable 'Region-Specific AI Disclosures' below.

Your Choices and Rights Regarding Our Use of AI

You have choices and rights regarding our use of AI and the processing of your personal information by these systems. These include:

• Access, Correction, and Deletion: You have the right to request access to, correction of inaccuracies in, or deletion of your personal information that we process, including data used by our AI systems, subject to applicable legal limitations. You can typically manage your account information directly through the Pathtide platform or by contacting us at support@Pathtide.com.
• Information about Automated Decisions: Where an automated decision significantly affects you, you have the right to obtain information about that decision-making process, as further detailed in our 'Automated Decision-Making (ADM) and Your Rights' clause and any applicable region-specific disclosures.
• Opt-Out of Certain AI Processing: Depending on your jurisdiction and the specific AI application, you may have the right to opt-out of certain types of AI processing, such as automated decision-making for significant decisions or certain types of profiling. Please see our 'Region-Specific AI Disclosures' for more details.
• Human Review: In situations where an automated decision has a legal or similarly significant effect on you, you may have the right to request human review of that decision, as provided by applicable law. To exercise these rights, please contact us using the details provided in the 'Contact Us' section of this Privacy Policy.

Region-Specific AI Disclosures

For California Residents (CCPA/CPRA & ADMT Regulations): In addition to your rights under the CCPA/CPRA, if you are a California resident, you have specific rights regarding our use of Automated Decision-Making Technology (ADMT) for 'significant decisions' as defined under California law.

• Right to Opt-Out of ADMT: If ADMT is used in your version of Pathtide’s platform or in the Offerings made available to you, You have the right to opt-out of Pathtide's use of ADMT for significant decisions concerning you, for extensive profiling, or for training ADMT. You can exercise this right by turning off this feature within your Pathtide platform or by contacting support@Pathtide.com for more information.
• Pre-Use Notice for ADMT: Before we use ADMT to process your personal information for a significant decision, we will provide you with a notice explaining the purpose of the ADMT, a general description of how it works, and information about your rights, including your right to opt-out.
• Right to Access Information about ADMT: You have the right to request information about our use of ADMT, including further details on how the ADMT works and the data it processes.

For Quebec Residents (Law 25): If you are a Quebec resident, Law 25 provides you with specific rights concerning decisions based exclusively on the automated processing of your personal information:

• Notification of Automated Decision: If a decision concerning you is made exclusively by an automated system, we will inform you of this no later than when we communicate the decision to you.
• Information Provided: This information will include the fact that the decision was automated, the personal information used to make the decision, the principal factors and parameters that led to the decision, and your right to have the personal information used to make the decision corrected.
• Right to Submit Observations and Request Review: You have the right to submit observations to a designated person within Pathtide who can review the decision if it has legal or other serious impacts on you.
• Consent: We adhere to Law 25's enhanced consent requirements for the collection and use of your personal information by AI systems, particularly for sensitive personal information.
• Privacy Impact Assessments (PIAs): We conduct PIAs for our AI systems and when transferring personal information outside of Quebec, as required by Law 25.

Security of Your Information in AI Systems

Pathtide is committed to protecting the security of your personal information. The robust security measures we implement across our platform, including encryption of data at rest and in transit, access controls, and secure hosting environments (e.g., on Amazon Web Services (AWS)), also apply to personal information processed by or used to train our AI systems. We regularly review and update our security practices to address evolving threats and maintain the confidentiality, integrity, and availability of your data within our AI operations.

Third-Party AI Services and Data Sharing

Some of Pathtide's AI-powered features may utilize technology or services from third-party providers, including, for example, ChatGPT, Claude, Gemini, and Meta. When you interact with such features, your personal information may be shared with and processed by these third parties for purposes including providing the AI functionality within our Offerings and services. We enter into contractual agreements with these third-party AI service providers. These agreements require them to:

• Protect the confidentiality and security of your personal information;
• Process your personal information only as instructed by Pathtide and only for the purpose of providing the contracted AI service to us;
• Not use your personal information for their own independent purposes, including for training their general AI models, unless explicitly stated otherwise in this Policy and, where required, with your consent.

We encourage you to review the privacy policies of any third-party AI providers mentioned if you wish to understand their data practices in more detail.

International Data Transfers Involving AI

Personal information processed by our AI systems may be stored and processed in countries outside of your country of residence, including in the United States where our primary data hosting services (AWS) are located. This may occur if you are located outside the U.S., or if our third-party AI service providers operate in other jurisdictions. When we transfer your personal information internationally, we do so in compliance with applicable data protection laws. We rely on legal mechanisms such as adequacy decisions (where applicable), contractual clauses, or your explicit consent for specific transfers, to ensure that your personal information receives an adequate level of protection in the recipient jurisdiction. Please be aware that when your information is in another jurisdiction, it may be accessed by the courts, law enforcement, and national security authorities of that jurisdiction.

Updates to this Privacy Policy

We may revise this Privacy Policy from time to time, in our sole discretion, and the most current version will always be posted on our Website (as reflected in the "Last Updated" heading). We encourage you to review this Privacy Policy regularly for any changes.

Contact information

If you have any questions about Pathtide’s Privacy Policy, the Personal Data we process associated with you, would like to exercise one of your data protection rights, have a complaint, or want to address any other issue, please do not hesitate to contact us.

As a reminder, when you do contact us, we want to make sure that we understand your request. So please state precisely and with specificity what you are wanting Pathtide to do or not to do. We will make reasonable efforts to comply with your requests as soon as reasonably practicable.

Simply put, by contacting us as detailed herein / below, you can choose to opt out, on a going-forward basis, from (a.) receiving text messages (simply reply “Stop” to any text to opt out), marketing emails and promotions and (b.) Pathtide’s sharing of your information (Personal Data or otherwise) and/or Data Collected with affiliates, third parties, and partners. Please know that if you choose to opt out, while we are unable to remove, from those databases of our affiliates, third parties, and partners, information/details already provided/disclosed, we will make reasonable efforts to remove such information/details from our databases and will stop sharing, to the extent we are lawfully allowed, such information/details with others. Please note that despite opting out of marketing related correspondence, Pathtide may still send you administrative messages.

Write to us at: Pathtide Inc., Attn: Privacy Department, Florida Tampa.

To reach our Data Protection Officer (DPO), please contact us via either https://www.PathtidePM.com/contact or support@PathtidePM.com.